Back in 2014, I wrote about six different universities and a community college that were all petitioning the FAA to become exempt from the requirement to hold a ground school certification so that they could participate in the R-ATP program.
That post had become somewhat stale, so here is a look back at what happened in the past few years.
Chandler-Gilbert Community College was denied its exemption in November 2017 and as of May 2018 was not authorized to certify R-ATP applicants.
Metropolitan State University of Denver was denied its exemption in July 2014 and as of May 2018 was not authorized to certify R-ATP applicants.
Denied and Then Authorized
Baylor University was denied its exemption in December 2014 and later gained R-ATP authorization in February 2016.
Eastern Michigan University was denied its exemption in August 2015 and later gained R-ATP authorization in July 2016.
Jacksonville University formally withdrew its petition for exemption in September 2016 and gained R-ATP authorization later that same month.
Auburn University was granted its exemption in November 2015, allowing Part 61 students who graduated between August 2010 and December 2016 to apply for R-ATP.
Purdue University was granted its exemption in July 2014, allowing Part 61 students who graduated between January 2009 and December 2016 to apply for R-ATP.
I previously wrote about a regulatory boo boo that made it impossible to determine how much cross country flying experience was required to obtain a restricted ATP certificate. The regulation that allowed students to apply for the rating with 30 college credit hours was never included in the nearby paragraph authorizing reduced cross-country time requirements.
Although this checklist is not regulatory, it is published by the FAA and so shows the original intent of the R-ATP regulation to allow anyone with 200 hours of cross-country time to apply for reduced minimums.
Since FAR § 61.160(e) contradicts the above checklist, I still anticipate a future amendment to fix this regulation.
Update: After 8 years, the FAA corrected paragraphs (d) and (e) as follows.
The FAA is also making a clarifying amendment to § 61.160(e) by adding a cross-reference that was inadvertently omitted in the Pilot Certification and Qualification Requirements for Air Carrier Operations final rule.As evident from the preamble to that final rule, § 61.160(e) was intended to “reduce the cross-country flight time required for all applicants for an R-ATP [airline transport pilot certificate with restricted privileges] certificate to 200 hours.”However, the express language of the rule provided relief only to those categories of applicants listed in paragraphs (a), (b), and (c). Because the relief in § 61.160(e) was intended for all eligible applicants,including persons eligible under § 61.160(d), the FAA is amending § 61.160 by adding a cross-reference to paragraph (d).
A search on federal websites revealed the FAA denied Eastern Michigan University’s exemption petition for R-ATP flight training last month. “The FAA has fully considered the petitioner’s supporting information and has determined the relief requested is not in the public interest and would adversely affect safety.” This decision is not surprising in light of the two-year delay and similar decisions preventing other Part 141 flight students from obtaining eligibility certification for a Restricted ATP check ride.
In its letter, the FAA gives this official response:
Based on the FAA’s records, EMU does not hold a part 141 ground school certificate. The FAA reviewed the description that EMU provided of its arrangement with EFC for the ground and flight training of students enrolled in its Aviation Flight Technology program. The arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum. EMU does not have control over the curriculum provided by EFC and the FAA would have no oversight responsibilities with EMU because it does not hold a part 141 pilot school certificate. Therefore, the FAA has determined that EMU’s aviation degree program does not meet the minimum level of integrating its pilot ground training with its broader academic curriculum of an aviation degree program.
Part 141 flight training graduates have been denied participation in the R-ATP program again, this time at Baylor University. In its recent denial letter, the FAA explained that even though Baylor’s students are enrolled in an aviation degree program with part 141 ground and flight training, the lack of a ground training certificate in the university’s name prevents the graduates from qualifying under the new regulations.
The FAA reviewed the description that Baylor provided of its arrangement with TSTC for the ground and flight training of students enrolled in its Aviation Science Bachelor degree program. The arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum by virtue of Baylor not holding an air agency certificate issued in accordance with part 141. Baylor does not have control over the curriculum provided by TSTC. As noted in the petition, Baylor students pursuing their instrument rating and commercial pilot training become TSTC students during those phases. Therefore, the FAA has determined that Baylor’s aviation degree program does not meet the minimum level of integrating its pilot ground training with its broader academic curriculum of an aviation degree program.
The Federal Aviation Administration (FAA) this week denied an exemption to the Metropolitan State University of Denver that would allow graduates of Part 61 flight training to become eligible for restricted ATP (R-ATP) certification. This is a complete reversal from the decision issued last week to Purdue University. In denying MSU Denver, the FAA writes, “the relief requested is not in the public interest and would adversely affect safety.”
Following that determination is a somewhat bizarre accounting of MSU Denver’s aviation program:
The proposed arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum. MSU Denver does not have any control over the curriculum provided by CNCC and the FAA would have no oversight responsibilities with MSU Denver because it does not hold a part 141 pilot school certificate.
The FAA notes that MSU Denver voluntarily surrendered its air agency certificate on April 19, 2013, and stated in its petition that it will continue to conduct training via part 61 vice part 141. Prior to the voluntary surrender of its part 141 pilot school certificate, MSU Denver held approved ground school training course outlines for the commercial pilot certificate and the instrument rating. Without a part 141 certificate, the FAA will not be able to determine if MSU Denver’s key personnel, facilities, aircraft, equipment, and training syllabus maintain a training standard that is equivalent to part 141. As stated above, the FAA has determined that meeting the part 141 standards are a necessary component to ensuring proper integration of the ground training with the broader academic curriculum and it enables the FAA to oversee the program and ensure continued compliance with the letter of authorization issued on an established 24-month schedule that coincides with the part 141 pilot school renewal. The FAA has concluded this oversight is critical for assuring that the standards set forth by Congress for a reduction in flight time continue to be met.
The FAA also notes that because MSU Denver previously held a part 141 pilot school certificate, graduates who completed their ground and flight training for their instrument rating and commercial pilot certificate under that training program could be eligible for a restricted privileges ATP certificate with reduced aeronautical experience without an exemption. MSU Denver has not yet applied for the authority to certify those graduates.
This decision is a significant setback for MSU Denver graduates, which creates a bad precedent for regulation of flight training in general. As stated in its petition, “MSU Denver will no longer be able to support industry needs and educational programming to highly diverse populations with the same viability it has sustained for over 45 years.” If the Part 141 university graduates are unable to qualify for R-ATP certification, then the value of Part 141 training is further reduced at all universities. Authorization of R-ATP qualification programs began in August 2013 and has reached only 33 States so far, leaving many Part 61 and Part 141 aviation graduates ineligible.
The Federal Aviation Administration (FAA) this week granted an exemption to Purdue University allowing graduates of Part 61 flight training to become eligible for restricted ATP (R-ATP) certification with reduced experience requirements. This exemption is retroactive. It is effective for all Purdue graduates from 2009 through 2016. The R-ATP check rides can be conducted through July 2017. Graduates are now only required to have an eligibility certificate from the university and a copy of the exemption letter from the FAA.
This exemption marks the first time the FAA has accepted R-ATP applicants who did not complete FAA-approved training under Parts 141 or 142. The requirement for airline pilots to hold an ATP or R-ATP certificate went into effect August 2013 and made no exceptions for university graduates who completed the same training under Part 61.
Purdue’s petition for exemption was dated 24 August 2013. Petitions from four other universities remain outstanding and were neither granted nor denied.
The FAA gave the following reasons for granting this exemption:
Purdue became a Part 141 flight school on 27 September 2013.
Purdue received authorization to certify R-ATP eligibility on 31 March 2014.
Purdue’s Part 141 ground training “is no different” from its former Part 61 program.
“Key personnel, facilities, aircraft, equipment, and training syllabus … also existed when Purdue conducted training under part 61.”
Several factors contributed to “an equivalent level of safety … for those who previously completed their ground and flight training.”
My searches on federal websites found four petitions by universities seeking R-ATP authorization without a required part 141 ground school certificate.
The petitioners are, in alphabetical order: Eastern Michigan University, Jacksonville University, Metropolitan State University of Denver, and Purdue University.
Letters and documents filed by these universities seem to be routine. I will point out also that the Jacksonville petition included a copy of the university’s rejection letter from the FAA dated December 2013.
While the FAA is not currently accepting comments on these petitions, I would like to offer my encouragement. The FAA should authorize these universities as rapidly as possible, recognizing they are accredited institutions that offer 4-year degrees with aviation concentrations. This is the purpose and intent of the R-ATP program, after all.
Details and reference numbers are listed below, in chronological order.
Goals, time building, industry changes, and future advancement. A look at the modern career pilot.
At the 500-hour milestone, experience comes more quickly for me. I enjoy six days per week at the airport, often arriving at 6:45 am and returning home by 8 or 9 pm. My schedule is not consistent, though. If I am training new students, the appointments always fall between 7 am and 5 pm. But the instrument students are scheduled by airplane availability, which means my shift sometimes begins at 4 pm and ends at midnight or 1 am. Fortunately, my company requires ten hours rest. I stay home and sleep if the schedule gets overbooked or loaded with back-to-back shifts. There is always a chance of bad weather or mechanical problems forcing cancellations within the schedule, which adds to the inconsistency.
A few years ago, someone in my position could spend their spare time looking into which airlines are hiring pilots, at which experience level, and at which locations. This changed with the addition of FAR § 121.436 last year, requiring all new airline pilots to hold an airline transport pilot certificate. I am not yet eligible to apply for that certificate, which has become my next career goal.
In terms of the calendar month when I could be ATP certified, there is no precise forecast. The situation is optimistic, but complex. Under the provisions of FAR § 61.160 (b), I could accumulate 1,000 hours of flight time within perhaps 4 to 12 months, and still have no expectation of eligibility.